ML25042A242
| ML25042A242 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/10/2024 |
| From: | Wang S US Dept of Commerce, National Marine Fisheries Service |
| To: | Arlene B NRC/NMSS/DREFS/ETRB1 |
| References | |
| Download: ML25042A242 (1) | |
Text
From:
Susan Wang - NOAA Federal To:
Briana Arlene Cc:
Sam Chin - NOAA Federal; Harrison Smith - NOAA Federal; Dan Lawson
Subject:
[External_Sender] Re: ESA/EFH Consultation: Diablo Canyon License Renewal - Additional Info request Date:
Wednesday, December 11, 2024 9:01:05 AM Attachments:
20241210_NMFS_Info_Request_NRC_DCPP_License_Renewal.docx Hi Briana, Sorry about that! I've attached the document!
Susan On Wed, Dec 11, 2024 at 5:57AM Briana Arlene <briana.arlene@nrc.gov> wrote:
Hi Susan,
Thank you. Unfortunately, I am unable to access the Google Doc. Im getting prompted to sign in with a gmail account, which I dont have for work. Could you forward your questions as an attachment? Thanks!
Briana Briana S. Arlene Conservation Biologist & ESA Consultation Coordinator Environmental Center of Expertise Office of Materials Safety and Safeguards U.S. Nuclear Regulatory Commission
briana.arlene@nrc.gov (301) 415-1042
From: Susan Wang - NOAA Federal <susan.wang@noaa.gov>
Sent: Tuesday, December 10, 2024 5:51 PM To: Briana Arlene <briana.arlene@nrc.gov>
Cc: Sam Chin - NOAA Federal <sam.chew.chin@noaa.gov>; Harrison Smith - NOAA Federal
<harrison.smith@noaa.gov>; Dan Lawson <Dan.Lawson@noaa.gov>
Subject:
[External_Sender] ESA/EFH Consultation: Diablo Canyon License Renewal - Additional Info request
Hi Briana, We reviewed the NRC's draft EIS for the Diablo Canyon License Renewal and identified some additional information we need from you for the ESA/EFH consultation request.
Please see our Comment/Questions/Additional Information Request in this Google Doc. If you have any issues accessing the Google Doc, let me know and I can re-share it as an attachment.
I think it would be helpful for us to discuss our comments and questions. Are you available this week? I am also available next week Thurs - Friday. I wanted to highlight a few of our major comments/questions/info requests:
- 1. Timeline for NRC's license renewal and when you need the ESA/EFH consultation completed.
- 2. Confirmation of the proposed action.
- 3. Additional data on discharge temperature data.
- 4. Additional information on discharge/effluent quality and constituents.
- 5. Black abalone: The effects analysis in the DEIS does not support NRC's NLAA determination, but instead indicates adverse effects. Happy to discuss this with you.
Thank you!
Susan Susan Wang Fishery Biologist, Protected Resources Division, West Coast Region NOAA Fisheries l U.S. Department of Commerce Office: (562) 980-4199 https://www.fisheries.noaa.gov/region/west-coast
NMFS Additional Info Request: NRC DCPP License Renewal, 12/10/2024 1
Consultation with NRC: Diablo Canyon Power Plant License Renewal NMFS Request for Additional Information and Comments on NRCs Draft EIS December 10, 2024 General Comments and Questions
- 1. Timeline: What is the NRCs timeline for the license renewal and when would you need the ESA/EFH consultation completed?
- 2. Proposed Action:
- a. Please confirm the Proposed Action is NRCs license renewal for DCPP Units 1 and 2 and, as a consequence, the continued operation of DCPP Units 1 and 2 for up to an additional 20 years beyond the current license expiration dates.
- b. Does the Proposed Action include dredging in Intake Cove or is dredging covered under a separate permit (not issued by NRC)?
- 3. Please provide copies of the following reports cited in the DEIS:
- a. Tenera (2000-29 TN10211) for fish entrainment
- b. Report documenting steelhead in Diablo Creek.
Specific Comments Executive Summary (1) Table ES-1, pg xxiv (pg 26): In Row 2, Column 3: remove gray whale (Eastern North Pacific DPS) and replace with gray whale (Western North Pacific DPS). The Western North Pacific DPS of gray whales is the DPS that may be affected by the proposed action.
Chp 2: Proposed Action (1) Please provide diagrams to illustrate what is described in the following sections:
(a) Section 2.1.3.1: DCPP once-through cooling water intake system and structure.
(b) Section 2.1.3.3: Auxiliary saltwater system.
(c) Section 2.1.3.5: Discharge system and structure.
(2) Discharge temperatures:
(a) Section 2.1.3.2: pg 2-6 (pg 50), lines 40 what is the range (minimum to maximum) in discharge temperatures (in °C above ambient intake seawater temperatures)?
NMFS Additional Info Request: NRC DCPP License Renewal, 12/10/2024 2
(b) The NPDES permit allows up to 22°F (12.2°C) above ambient intake temp, except during heat treatment for demusseling when up to 25°F (13.8°C) above the daily average intake water temp is allowed. Could you provide figures (or summary text) describing how much of this allowable temperature rise is typically used, if such data are collected/available?
(c) Section 2.1.3.5 How is the temperature rise (maximum of 22°F or 12.2°C allowed per the NPDES permit) measured? How often is it measured? How is the extent of the plume monitored (e.g., sensors, diver surveys)?
(d) Section 2.1.3.5 (Discharge system; pg. 2-7 or 51, lines 38-39): What is meant by The width of the discharge flow out of the mouth of the structure is 27.5 ft (8.4 m) per unit.?
(3) Section 2.1.3.4 Chemical treatment system: Please provide data or figures showing the levels of chlorine and other constituents discharged in the effluent (max and average effluent levels over the past 5 years and the frequency of monitoring).
(4) Section 2.1.3.6 (Desalination system):
(a) Please clarify if this is a desalinization system or a desalination system.
(b) What is the volume of brine generated and where/how is it discharged?
(c) Please provide data or figures showing the effluent quality of the brine.
Chp 3: Affected Environment (1) Section 3.5.1 (Surface Water Resources), pg 3-31 (pg 97), lines 10-15: Lines 10-13 indicate that the "impassable barrier" on Diablo Creek is the DCPP's switchyard.
However, lines 13-15 also state that Diablo Creek discharges into Diablo Cove. Please clarify - does the culvert provide downstream passage for fish, including steelhead?
(2) Section 3.5.1.3.2 NPDES Permitting Status and Plant Effluents (pg. 3-38, pg 104): Lines 1-8 mention RWMP annual reports and monitoring stations. Please provide a map showing the monitoring locations and also a link to where we can access the RWMP annual reports.
(3) Section 3.3.4.2 The determination of SMALL for noise seems to have been made relative to how the LR would affect current operations. Has there been any monitoring done to study how noise from current operations may be affecting the surrounding environment at DCPP?
(4) Section 3.7.5.1 Have there been any IM or entrainment studies within the past 10 years?
NMFS Additional Info Request: NRC DCPP License Renewal, 12/10/2024 3
Effects Analysis for Species and Critical Habitat Black abalone and black abalone critical habitat (1) Section 3.8.1.3 NMFS ESA Species and CH, Table 3.12: The text in other sections of the DEIS indicate black abalone were observed in Diablo Cove prior to 1988.
(2) Section 3.8.4.2.1 Black abalone and their critical habitat (pg. 3-127, pg. 193)
(a) Please provide a map of survey sites in Discharge Cove, Intake Cove, and surrounding areas within the action area. Indicate the years surveys were conducted and where reports can be accessed from the 1980s to 1990s (spanning the years before, during, and after DCPP operations began).
(b) Inconsistent statements in the text that black abalone have been present in Diablo Cove since the late 1980s, but that black abalone were observed in high densities in the early 1980s.
(c) When did construction of DCPP Units 1 and 2 and the Intake and Discharge structures occur?
(d) Pg. 3-129 (pg. 195): What is the temperature within the area directly affected by the thermal discharge (directly in front of and adjacent to the discharge)?
(e) Please provide any data available on the presence of black abalone in the Intake Cove prior to, during, and after DCPP operations began.
(3) The effects analysis indicates adverse effects on black abalone and their critical habitat.
For example, the language in Table 3-16 (pg 3-124, pg 190) states that continued thermal effluent discharges may cause black abalone to avoid the region of highest water temperatures immediately adjacent to the discharge structure. Because the plant has been operating for several decades, this would result in continued avoidance rather than displacement of individuals.
(a) We would like to discuss NRCs NLAA conclusion, because the effects analysis in the DEIS indicates adverse effects (LAA). Given this, black abalone would be included in the formal consultation.
Sunflower sea star The DEIS provides information on sunflower sea stars from recent surveys in and around Intake Cove.
(1) Have recent surveys been conducted in and around Diablo Cove? If so, please provide a summary of the survey results for sunflower sea stars, to further support the statement that sunflower sea stars are not present in the action area.
(2) If there is the potential for sunflower sea stars to be present in the action area, please evaluate the potential for the proposed action to adversely affect sunflower sea stars.
Steelhead We shared information about the impassable barriers with our steelhead team and are waiting for their comments.
NMFS Additional Info Request: NRC DCPP License Renewal, 12/10/2024 4
Leatherback Sea Turtle Critical Habitat The DEIS (pg. 3-111 or pg 177, lines 37-38) states that jellyfish may be present in the action area, though none have been specifically identified in ecological studies of the area.
(1) Please provide any additional information from NRC/PG&E to indicate the presence/absence of jellyfish, or likelihood of presence, in the action area.
(2) If there is potential for jellyfish to be present in the action area, please evaluate the potential for the proposed action to adversely affect jellyfish (as a component of leatherback sea turtle critical habitat).